Memorandum Opinion
GUSSIS, Special Trial Judge:
This case was assigned for trial pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182. All section references are to the Internal Revenue Code in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.
Respondent determined a deficiency in petitioners' Federal income tax for 1986 in the amount of $6...
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